1. PRODUCT LINE LEAK DETECTION (including a summary of the 2015 UST regulations) Katie Seaborn AMERICAN CONTAINMENT SERVICES, INC. ® Annual GTEC Underground Storage Tank Management & Compliance Seminar – 2015

2. Angle Check Valve OR Foot Check Valve SUCTION PUMP Under Pump Check Valve UST 1. Common Method Product Pipe 2. Safe-Suction Method Suction Systems

3. SUCTION SYSTEM Leak Detection Requirements: For COMMON systems (one is required):  Product Pipe Tightness Test Every 3-Years  Monthly Interstitial Monitoring  Monthly Groundwater OR Vapor Monitoring  Monthly Statistical Inventory Reconciliation For SAFE-SUCTION systems (all are required):  Piping must slope back to the tank.  Only one check valve, and it must be installed as close as practical to the pump.  The above must be verifiable.

4. Dispenser Shear Valve UST Double-Wall Product Pipe Submerged Turbine Pump Pump Motor Pump Head Pressurized Systems

5. Must be equipped with an automatic line leak detector which must be tested annually, AND use one of the following:  Annual Line Tightness Testing  Monthly Secondary Containment Monitoring  Monthly Vapor or Groundwater Monitoring  Monthly SIR Additionally, the following is also required:  Annual Tank Gauge System Inspection  Monthly Walk-Through Insp. w/ATG Check PRESSURIZED SYSTEM Leak Detection Requirements:

6. Federal EPA Requirements for Automatic Line Leak Detectors (LLDs):  Can detect a 3-gallon per hour leak, at a line pressure of 10-psi, within 1-hour.  When a leak is detected, LLDs must shut off the product flow, restrict the product flow, or trigger an audible or visual alarm.  Must have a Third Party Certification.  Must be tested for proper operation annually. More PRESSURIZED SYSTEM Leak Detection Requirements:

7. Requirements for containment sumps used for interstitial monitoring of piping:  If double-walled, the integrity of both sump walls must be monitored monthly.  Must be visually inspected annually.  Must be tightness tested every 3-years, using pressure-decay or hydrostatic method, in accordance with the manufacturer, a nationally recognized industry standard, or other method determined by the implementing agency. Leak Detection for SECONDARY CONTAINMENT / INTERSTICES:

8.  No leaks at the STP or leak detector  No reduced flow  No liquids in secondary containment or containment interstices  No alarms on electronic monitoring devices PRESSURIZED SYSTEM Leak Detection Summary Checklists: Monthly Annually  Leak Detector Functionality Testing  Product Line Tightness Testing  Visual Inspection of all accessible piping, fittings, and secondary containment  ATG System Inspection and Functionality Test

9. (Electronic Sump Sensor) FE Petro MLLD Mechanical Pressurized Line Leak Detectors (MLLDs) Red Jacket MLLD

10. Electronic Pressurized Line Leak Detectors (PLLDs) Incon PLLD’s V/R PLLD’s (Wireless PLLD) Should be tested annually for proper detection of a leak at 3-Gallons-Per-Hour (GPH), 0.2-GPH, and 1.0-GPH.

11. MORE 40 CFR 280 Regulations  Emergency Generator Tanks are no longer Deferred!  Must perform walkthrough inspections every 30-days. PEI RP 1200 “Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities” and PEI RP 1200 “Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities” and PEI RP 900 “Recommended Practices for the Inspection and Maintenance of UST Systems” PEI RP 900 “Recommended Practices for the Inspection and Maintenance of UST Systems”  It is recommended that all records related to walkthrough inspections, periodic tests, repairs, and maintenance be maintained for a minimum of 3-years.  Important revisions to 40 CFR 280.50 and 280.52, regarding response to interstitial/secondary containment alarms and suspected release reporting.

12. POP QUIZ! What kind of system is it, and what is required? Common Suction Method Safe-Suction Method Pressurized Line PTT Every 3-yrs, OR Interstitial Monitoring, OR Stat. Inv. Reconciliation No Leak Detection Required for the Product Piping PUMP UST PUMP UST PUMP UST Annual LD Test AND Annual Line PTT, OR Interstice Monitoring, OR Stat. Inv. Reconciliation

13. POP QUIZ!... continued POP QUIZ!... continued What kind of system is it, and what is required? Annual Line PTT OR Stat. Inv. Reconciliation AND Interstice Monitoring (if piping is double-wall) Note: an anti-siphon valve is also a really good idea in this configuration! UST GRAVITY/SIPHON SOLENOID VALVE

14. POP QUIZ!... (last question) What kind of system is it, and what is required? UST PUMP EMERGENCY POWER GENERATOR SOLENOID VALVES ATTENTION!! Leak Detection is no longer deferred for Emergency Power Generator Systems GRAVITY/SIPHON Requirements are the same as the previous slide.

15. Examples of what not to do…

16. … what is leak detection really all about? At the end of the day…. Any questions? Photograph courtesy of Mike Moreland Photography Photograph courtesy of Mommy with her camera